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ADEQUACY RESPONSES TO COLORADO DIVISION OF OCT 191992 <br />MINING AND GEOLOGY ADE TS 0, ...,. <br />TO TECHNICAL R ON NO. 9 - ,nr;EP,a~c ~, <br />SURFACE WATER AND GROUNll ~ T (LEAN <br />RELATED TO POTENTIAL CONTAMINANT MIGRATION R0~4 TIIE <br />TAILINGS AREA, SAN LUIS GOLD PROJEC , <br />COSTILLA COUNTY, COLORADO <br />~~~~~~ <br />COMMENTS BY JAMES C. STEVENS ~~ p ~~i <br />1. The drilling and testing of the additional monitoring wells approved in TR-08, <br />comprising Phase ! of this proposal, will not be cornpletetl in time frtr evnluation <br />ofthe data, development of a ground water conminnrcnt plan, and IDivision review <br />by the mandated decision data of July I5, 1992 for TR-09. <br />BMR should waive their right to a decision on TR-09 ny July I5, 1992 to provide <br />enough [ime to asscnrble the data, evaluate, antt propose n ground water <br />containment plan that could be considered by tJre Division fin• ap/Iruval. <br />RESPONSE: BMR received acknowledgment of the acceptance of TR-08 on July 2, 1992. At <br />that time, BMR initiated the necessary tasks to comply with ~R-08 and the <br />drilling and testing of the additional monitoring +vells was completed during the <br />period July 20, 1992 through July 28, 1992. Therefore, BMR Chas agreed to <br />waive its right to a decision on TR-09 by July 15, 1992. <br />2. 77tere is some doubt that the Division +vill be provided with the results rf the <br />second phase, i.e., darn evnhmtion, of the development of the proposed grorurd <br />water containment plan. 77te cover letter indicates "if treces.caty ", 4hhorrgh page <br />2 of the proposal cotmnits to submitting dtis "docutneruation to CMLRD ". <br />77te Division considers it necessary to its detennitratiotrs and review q~ DMR's <br />proposed ground wafer containment plan, whatever that may be, drat all testing <br />data, descriptions, modelling amd evaluations made in conjunction ntilh or leading <br />to BMR's proposal be provided. Ifdtis is not entirely agreeable to BMR, i. e., if <br />there are conditions to submittal of this data nn BMR's port, the proposal shrndd <br />clearly state these conditions. <br />RESPONSE: As stated in John C. Halepaska and Associates, Inc.'s (JCHA) TR-09 submittal, <br />"[f]ollowing the CMLRD approval of the program [TR-08] and its implementation <br />by Battle Mountain, Battle Mountain will submit separate documentation to <br />